Dog Food Watch: Recalls

We’re barely halfway into the year and already, there have been a flurry of pet food recalls. The sheer number of brands has been surprising, as have the names of the brands involved; we’ve seen recalls from some of the industry’s most respected companies. How and what we feed our dogs (and ourselves, for that matter) is such a fundamental issue that we’ve decided to do a series of articles on pet food safety, starting with a report on a few of the most recent recalls. We examine the reasons behind them, lessons learned and what we might expect in the future.

Until very recently, all recalls have been voluntary (a confusing term that can lead consumers to believe that a recall is optional), triggered for a variety of reasons: mislabeling, misbranding, the inclusion of potential allergens or adulterants, or contamination with a pathogen such as one of the varieties of salmonella. And some products are recalled simply because they were produced at the same factory during the same timeframe as the affected food.

So far, no pet food recall has been as widespread as the one in 2007, which involved the Menu melamine scandal. If Hurricane Katrina taught policymakers the importance of the human/ pet bond, the ’07 Menu Foods recall did the same for the focus on the safety of the food that we feed our pets. As William Hubbard, a former FDA official, notes, “I do think that this pet food thing has shown people … that something needs to be fixed. If this is not a wake-up call, then people are so asleep, they are catatonic.”

It took a while for Congress to fully awaken, but in 2010, the Food and Drug Administration (FDA) was given more power with the passage and then signing into law by President Obama of the Food Safety Modernization Act (FSMA). The act marks the most sweeping food-safety reform since the Great Depression.

This new act will soon be putting broader issues into the spotlight. For the first time, the FDA will be empowered to more aggressively regulate and enforce preventive measures. Recalls will no longer just be voluntary, but rather, can be mandatory. In our opinion, given this new regulatory power and the plethora of places from which pet food manufacturers source their ingredients, the number of recalls will surely rise. Closer attention and accountability are good for consumers and the animals we feed, and definitely something we need to be informed about.

RECALL CLASS OF 2013
Six years ago, in 2007, veterinarians began seeing a surprising number of companion animals—primarily dogs—with kidney problems; in September of that year, the American Veterinary Medical Association alerted the FDA that they had had reports of a Fanconi syndrome–like disease that appeared to be associated with the consumption of chicken jerky treats made in China. As a result, the FDA issued its first cautionary warning—not a recall—for those treats. In early January 2013, after the FDA had spent years investigating whether or not jerky treats from China were harming (and killing) pets, these treats were finally voluntarily recalled.

We have the New York State Department of Agriculture and Markets to thank for finding what might be the contributing factor: the department identified antibiotic residues not approved for poultry in the U.S. in the treats. This spurred Del Monte, the makers of Milo’s Kitchen Chicken Jerky Treats, and Nestle Purina, manufacturers of Waggin’ Train and Canyon Creek Ranch dog treats, as well as others, to finally initiate a nationwide removal of these products from store shelves.

Though the FDA continued to claim that “there is no evidence that raises health concerns, and that these results are highly unlikely to be related to the reports of illnesses,” the findings were enough to convince the slow-moving food industry that they needed to get the products out of circulation. The FDA, which still considers this to be an open investigation, notes that they “welcome additional information about New York’s testing methodology …” To date, the treats are thought to have contributed to the deaths of roughly 500 dogs and nine cats. If New York’s state inspectors had not found the illegal antibiotic residue, those treats would still be available. Chalk one up for the state team!

DOMESTIC PRODUCTS TAKE A HIT
Over the past few years, consumers have learned to look for “Made in the U.S.” to guide their food purchases. So it was a surprise when a U.S. manufacturer of jerky and other “animal-parts” treats like bully sticks and pig ears issued a large-scale recall. This time, salmonella —a group of bacteria responsible for most cases of human food poisoning— was the culprit. Again, inspectors from a state department of agriculture, this time in Denver, Colo., were responsible for identifying the problem. In September 2012, during a routine check of the Kasel Associated Industries processing plant, inspectors found evidence of salmonella contamination. The firm issued three recall notices that year, one in September and two in October.

In February of this year, Kasel had the dubious distinction of being the first pet food manufacturer to possibly face a first-ever FDA/FSMA mandatory recall notice, a threat based on inspections by an FDA team that found a number of infractions: “All of the finished pet treat product samples and 48 out of 87 environmental samples collected during the inspection tested positive for salmonella. More than 10 different species of salmonella were found in the firm’s products and manufacturing facility, indicating multiple sources of contamination.” The jerky treats were sold through a number of big-box retailers, including Target, Petco, Sam’s Club and Costco.

Other jerky products made in Kasel’s Denver plant were drawn into the recall as well. Bixbi, an up-and-coming independent brand from Boulder, had batches of their products swept up, and Nutri-Vet, a more established brand, was also named, although it was noted that none of these products had tested positive for bacteria. (I contacted the owners of Bixbi and Kasel, who responded to my questions; I also placed numerous calls to Nutri-Vet, who didn’t reply.)

Treats aren’t the only products in which salmonella has been found, however. Natura, a premium holistic brand now owned by Procter & Gamble, had its first recall experience this year after one of their dry-food products tested positive for salmonella by Michigan inspectors. When I spoke in late March to Jason Taylor, a P&G spokesperson, he said the company was still in the process of trying to recreate the production situation at the time the contamination happened; they were, however, sure that it had occurred during a post-extrusion step. “We have an extrusion [cooking] process that is scientifically proven to kill pathogens … So it probably happened either at the dryer or packaging line.” According to Taylor, the company has a complex manufacturing process in place to ensure that their products are contamination- free. Their microbial-mitigation process, which has more than 100 steps, addresses each step the food goes through, from raw material through packaging.

Taylor said that the company was fairly confident that the problem was limited to products manufactured during the two-week period beginning December 17, 2012, and ending January 2, 2013. Since then, we learned that they extended the recall for products manufactured up through March 24, 2013— making this a larger-scale recall.

RAW FOOD PRODUCTS UNDER THE MICROSCOPE
Pet-food safety advocates wondered if the FDA was exerting more muscle on domestic manufacturers to make up for their foot-dragging on Chinese jerky. Then the recalls moved into the raw-food realm. The first, also in February, involved Honest Kitchen’s recall of limited lots of Verve®, Zeal® and Thrive® products. Honest Kitchen has a transparent, consumer-friendly approach to their food sourcing, and in their recall notice, founder and CEO Lucy Postins noted that “the Company is taking this action after learning that one of its raw ingredients suppliers has recalled a batch of human-grade parsley that may contain salmonella.” The parsley— which had come with a certificate of analysis from the supplier attesting that it was pathogen-free—had been used in the production of five lots of finished products.

While most of Honest Kitchen’s rawfood sources are in North America, they also get some produce from Europe and exotic fruits from Asia. Surprisingly, they get their parsley from Egypt. Yearround availability of organic and/or human-grade ingredients at a reasonable price is one of the challenges faced by smaller food manufacturers like Honest Kitchen, and is the reason for this wide-ranging sourcing.

Since this incident, Honest Kitchen has switched to another parsley supplier (also in Egypt) and added a new step to their processing of dried herbs and leafy greens, treating them with a gentle steam sterilization to protect against microbial pathogens.

More raw food companies were hit with recalls in March, when the Minnesota State Department of Agriculture found salmonella, first in Steve’s Real Food Turducken patties, and a week later in a two-pound tube of Bravo! Chicken Blend raw frozen food diet the agency had purchased from a local pet store.* I talked with veterinarian Heidi Kassenborg, director of Dairy and Food Inspections for Minnesota, to get a better idea about her state’s pathogen inspection process.

Many have observed that while salmonella is the most prevalent foodborne pathogen, few dogs actually become ill from it, and I asked her why the FDA and her agency have such a strong concern about its presence in pet food. She explained that they are charged with finding adulterants in food, and “in food items, salmonella is considered to be an adulterant.” As for the USDA’s salmonella-tolerance level for raw poultry (now at 7.5 percent, down from 20 percent in 1996), she confirmed that “in raw food, like poultry and beef, it is not considered to be an adulterant.” Basically, there is no tolerance for adulterants in finished food items, and even raw diet is considered a “food item.”

Kassenborg explained the high concern about pet food, saying that since pet food is handled by humans, they are exposed to any pathogens that may be in it; these pathogens can also be excreted in the pet’s stool. Given that salmonella can cause serious and sometimes fatal infections in young children, the frail or elderly, and those with weakened immune systems, this is indeed a compelling reason for concern.

She went on to say that there would be increased surveillance now that raw diet has tested positive for pathogens. “Once things are found in one food type, they start looking at it and testing more. We have an obligation to find out if it is a widespread problem. And if so, is there a way to produce it better without it becoming contaminated?”

Doug Lueders, supervisor of Minnesota’s Commercial Feed Regulatory Program and the person responsible for its product-sampling plan, concurs. “If we have a category that has had few [contaminants] or none, we may switch our emphasis to one where we have had a problem. I think we will raise the percentage [of resources] that we have devoted to raw in the past; that, however, will be at the expense of something else.”

Resource allocation is a real issue. Other states have registered positive hits on items like jerky and kibble, so even though there might not be direct interstate coordination of efforts, Lueders says, since “Michigan found salmonella in one brand of pet food, it probably doesn’t serve much practical purpose for us to look at the same brand ourselves. There is an old adage that says an absence of evidence is not evidence of absence, so we wouldn’t continue to test the same pet food for salmonella in hopes of finding more salmonella, or hoping to find that it is clean …”

THE PRICE OF SAFETY
What impact does this have on consumers and the pet food industry— in particular, the raw-diet industry? For an answer to that question, I turned to Melinda Miller, president of North American Raw Petfood Association (NARPA), a trade organization. She acknowledges that positive findings— which she says are likely to increase once the FSMA legislation is fully implemented—have an impact on NARPA members; she also notes that the leading raw-diet manufacturers subject their processes to more vigilance and testing than occurs in any other pet-food sector.

Prior to processing a food in their facilities, suppliers must certify that the food is pathogen-free. Throughout the manufacturing process, pathogens are tested for and eradicated. A few NARPA members use what is known as highpressure processing or high-pressure pasteurization (HPP), which disrupts a pathogen’s cell walls. Miller says that this very expensive system is considered by the general food industry to be stateof- the-art in controlling pathogens.

Companies like Bravo! also batchtest and follow a test-and-hold system, meaning that finished products are not shipped from their plants until negative pathogen reports are in hand. A Bravo! spokesperson described the company’s process: “Most established companies in raw diet own their own facilities. We [at Bravo] come out of the meat business and our facility is a USDA facility for human food, so we have standards we have to keep up. We have a USDA inspector who checks the plant daily to make sure that [things are] being done by the books [and] we have a HACCP [Hazard Analysis Critical Control Points] plan in place. What consumers should be looking for are companies who use ‘test and release’ and batch testing, and have HACCP plans.” He also noted that the company’s website will soon have a function that will allow consumers to enter an item number and “best used by” date and receive test results for E. coli, Listeria and salmonella.

This type of high-level testing increases the cost of the final product; as Miller observes, “you can’t add a whole level of pathogen controls and not have a resulting increase in cost to consumers.”

THE BOTTOM LINE
No business undertakes a recall lightly — it’s the last thing any food manufacturer wants to do. Not only are recalls costly, they have the potential to harm a brand’s image.

But while smaller brands can be devastated by such events, companies who have worked hard and long to develop a loyal customer base can, most likely, recover from them, as can internationally distributed brands such as Natura.

I don’t believe that most of these pet food companies and manufacturers acted recklessly. But after a recall, it shouldn’t be business as usual. Measures need to be taken to identify where the contamination came into the system, and pathogen controls need to be improved. Changes need to be made—for some businesses, that may mean switching manufacturers, raw-material suppliers, warehouses or distributors, or even instructing pet stores on proper handling and storage techniques for their products.

It’s also critically important that they pay attention to how customers are notified (and receive compensation or refunds). For example, I commend Honest Kitchen for quickly alerting its customers via email, social media and website notices. Retaining the trust of customers requires companies to be transparent, forthcoming and ready to make production and sourcing modifications, as they and a few other companies have done.

Realistically speaking, it’s unlikely that the food system can be made 100 percent safe. Nonetheless, we need to know we can trust that those who make the food we feed our companion animals are held to the same standards as those who supply the food we eat ourselves.

Over the years, we’ve become well aware of the concept of food sourcing. In addition to knowing exactly what goes into the food we feed our dogs and cats, we also need to know where it comes from. How the finished products are processed, packaged and distributed is also vitally important. As P&G’s Taylor observed, pathogen elimination is challenging when working with large quantities of raw meat and poultry.

Do some food processors take shortcuts to save money? For some, that might be the case, as evidenced by the huge 2012 recall involving a Diamond co-processing plant in Gaston, S.C. , which ultimately affected 17 brands representing more than 30,000 tons of dry dog and cat food. Because a rare strain of Salmonella infantis was found in some product samples, all brands, ranging from high-end Wellness to Costco’s brand, Kirkland, were recalled. According to the Centers for Disease Control and Prevention, at least 49 people in 20 states and two in Canada who came in contact with pet food made at this facility are confirmed to have been affected. When the FDA inspected the plant, they found numerous problems with the contamination-containment processes, including the use of cardboard and duct tape on some of the equipment. How they got away with this—how they managed to fly under the radar of the companies for which they were making food—is anyone’s guess.

Yet another problem that cries out for better monitoring involves actually getting recalled products off store shelves. A reporter for a Colorado television station found bags of the tainted Chinese jerky in stores such as Safeway, K-Mart and Albertsons almost a month after it had been recalled. I learned about this from attorney Jennifer Reba Edwards of the Animal Law Center in Wheat Ridge, Colo. As Edwards points out, “The bigger problem is [that] once recalled, the products are still getting to the end user. Retailers are not pulling the products from the shelf and you can buy them online; that is almost a bigger problem than the recall itself—preventing it [from] being available to the end user.” Who is responsible for this step? Who should be held accountable? This is definitely a problem to track and one that consumers need to be aware of.

Within the dog community, the issue of salmonella is controversial; some question its potential to harm dogs. However, I don’t believe this is debatable. There are too many instances in which people have been damaged by cross-contamination or mishandling in the home of food intended for pets. The FDA considers it to be an adulterant in both human and animal foods, as well they should. More to the point, as Jennifer Edwards says, “I’m pregnant; I would really be upset if I were to be exposed to salmonella. It goes beyond protecting our animals—we have to protect our people as well.”

If ever there was a reason to look at the big picture, this is it. We have only one food supply, and it should be safe for both humans and animals. This is, and ought to be, the standard that foodsafety regulators, the food industry and we—the consumers—need to meet.

*A Bravo! company spokesperson told me that the product that tested positive had been tested by a third-party inspector before leaving the plant and had a negative-contamination finding. In an unusual step, the FDA allowed that point to be included in their recall statement.

BEST PRACTICES
> Save packaging or keep records of UPC codes and expiration dates from pet food bags/cans.
> Use a smartphone to photograph package codes.
> Store dry kibble in its bag inside an airtight container.
> Do not mix different batches of kibble.
> Do not use a feeding bowl as a scooping utensil.
> Wash all surfaces and utensils that come in contact with dog food.
> Wash feeding bowls after each meal (wash water bowls regularly, too).
> Wash hands for 20 seconds with warm soapy water after handling pet food.
> If a product has been recalled, save a sample in a sealable bag before disposing of the rest of product properly—in a plastic trash bag securely tied.
> When choosing a new pet food, do your homework: make sure the company has a transparent and open method of posting recall information and contacting customers, provides clear repayment instructions, and lists ingredients and, ideally, their sourcing.
> Avoid large chain stores; shop small and local.